Gully v Varghese
SC New York · May 12, 2026
What happened in this matter?
The court struck the plaintiff's summary judgment motion and reply memorandum because they relied on fabricated case law. The judge determined that the citations were AI-generated hallucinations and that the plaintiff's pro se status did not exempt her from the obligation to verify the accuracy of legal authorities presented to the court.
- Why the court cared
- The court reasoned that filing papers with fabricated legal authorities is sanctionable as frivolous conduct under 22 NYCRR 130-1.1. The judge emphasized that pro se litigants are held to the same standards as represented parties regarding the duty to ensure the authenticity of cited authorities. The court determined that striking the offending submissions was the most appropriate consequence, finding that the plaintiff's failure to verify the citations undermined the truth-seeking function of the judicial system.
- Why it matters now
- This case illustrates the judicial response to pro se litigants using AI-generated fake citations. It reinforces that courts will strike filings containing hallucinated authorities regardless of the filer's intent or representation status, emphasizing the duty of reasonable inquiry.
Why this matter is tracked
In this tort action, the pro se plaintiff submitted a summary judgment motion and reply memorandum containing three fabricated case citations. The court identified these as AI-generated hallucinations. The plaintiff admitted to the inclusion of the non-existent cases but claimed they were unintentional and inadvertent. The court found that the submission of fabricated legal authorities constitutes frivolous conduct, noting that pro se status does not excuse a litigant from the duty to verify the authenticity of cited authorities. Consequently, the court struck the plaintiff's submissions containing the false citations and denied her motion for summary judgment. The court declined to impose additional monetary sanctions, citing the plaintiff's pro se status and the severity of the existing sanction.
This case illustrates the judicial response to pro se litigants using AI-generated fake citations. It reinforces that courts will strike filings containing hallucinated authorities regardless of the filer's intent or representation status, emphasizing the duty of reasonable inquiry.
Record details
What the record establishes about AI use
The court noted the citations appear to be hallucinations created by an artificial intelligence tool.
The court addressed the plaintiff's motion for summary judgment and the defendants' cross-motion for summary judgment, alongside the plaintiff's motion to strike the defendants' bill of particulars, in a decision dated May 12, 2026.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
3 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiff cited this non-existent Appellate Division decision in support of her summary judgment; court found the citation fabricated and struck the submission.
- Fabricated: Case Law | Plaintiff cited this non-existent Appellate Division decision in support of her summary judgment; court found the citation fabricated and struck the submission.
- Fabricated: Case Law | Plaintiff cited this non-existent Appellate Division decision in support of her summary judgment; court found the citation fabricated and struck the submission.
Questions this record answers
- What happened in Gully v Varghese?
- The court struck the plaintiff's summary judgment motion and reply memorandum because they relied on fabricated case law. The judge determined that the citations were AI-generated hallucinations and that the plaintiff's pro se status did not exempt her from the obligation to verify the accuracy of legal authorities presented to the court.
- Why does Gully v Varghese matter for legal AI risk?
- This case illustrates the judicial response to pro se litigants using AI-generated fake citations. It reinforces that courts will strike filings containing hallucinated authorities regardless of the filer's intent or representation status, emphasizing the duty of reasonable inquiry.
- What does the public record establish about Gully v Varghese?
- The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Gully v Varghese summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.